“Ghana should include OHS elements in academic curricula and legal requirements. An organisation should be set up with specific roles and responsibilities to focus small, scattered efforts by different agencies, and improve on the approach, and implement measure uniformly.”
Joe-Steve Annan (MSc Quality Safety and Environment; BSc Chem Eng; American Industrial Hygienists Association member), in a paper titled ‘Occupational and industrial safety and health’ on Ghana Web, called for integration of health and safety enforcement, resources, and management measures under one organisation in Ghana.
Accelerated industrialisation in Ghana exposes more Ghanaian workers to workplace physical, chemical, biological and psychological stressors. The country has inadequate measures to anticipate, prevent, monitor, evaluate and control health and safety risk exposure.
Ghana’s current OHS situation
Employers in Ghana are required by the Ghana Labour Act 2003, Act 651 to ensure their employees are not exposed to conditions that would lead them to work related injuries or illnesses. Employees are also required to exhibit their duty of care in ensuring that they work as per the employers’ standard operating procedures which must incorporate Safety and Health requirements. However, most Ghanaian workers and employers are not aware of their safety and health responsibilities and obligations.
Various industries like Mining, Construction, Energy, Food Processing, Manufacturing, Agro, Transport and lately Oil and Gas in Ghana has lead to a large Ghanaian workforce with many Similar Exposure Groups (SEGs), indicating varying modes, extents and frequencies of exposures to different Chemical, Physical, Ergonomic and Biological agents at different workplace.
There is a Ghana Road Safety Commission, but with little standards, guidelines or impact on transport industry or public road users.
Ghana has different agencies under different jurisdictions which monitor different industries for workplace and employee safety, however there is no national body, policy nor process that govern Occupational Safety & Health management in Ghana.
The Minerals Commission has the Mining Regulations of 1970, which contains some guidelines in Occupational Safety and Health but just for the Mining Industry. This is being reviewed as Mining and Minerals Regulations.
Incidents not reported
Numerous injuries, illnesses, property damages and process losses take place at different workplaces but due to under reporting or misclassification due to lack or thorough standards, or unfamiliarity with the existing guidelines, people are not normally in the known of such events as well as their actual or potential consequences and effective corrective actions required.
Too many safety organisations
Given the wide range of potential and/or actual undesired events associated with the myriad of work groups in Ghana, there is the need to have a comprehensive provision for occupational safety and health standards and practice in the nation, with an unflinching national leadership, support and commitment. However, the situation as it stands suggests otherwise, hence this paper provides suggested approach in improving on the practice, management and monitoring of occupational safety and health in Ghana.
Three edicts have provided guidance in the provision of occupational or industrial safety and health services, practice and management in Ghana;
* Factories, Offices and Shops Act of 1970, Act 328
* Mining Regulations of 1970, LI 665
* Workmen’s Compensation Law of 1987, PNDC 187 for personal injuries caused by accidents at work.
The Radiation Protection Board of the Ghana Atomic Energy Commission is also proactive in monitoring companies with radiation exposure hazards for compliance, however, due to limited resources, effectiveness of their activities is compromised.
Few safety inspections in Ghana
On a proactive side, the Ghana Chamber of Mines in collaboration with the Inspectorate Division of the Minerals Commission form a Technical Committee with representations from each mining company in the nation that reviews and recommends corrective actions for reported or identified unsafe acts, conditions or failures in the existing Health and Safety system of the mining industry. This good initiative is however impeded by availability of resources and hence enforcement is challenged.
There are other statutes which indirectly impact on Occupational Safety and Health;
• Environmental Protection Agency Act 490 of 1994
• Ghana Health Service and Teaching Hospital Act 526 of 1999
• National Road Safety Commission Act 567 of 1999.
ILO convention rules
Ghana is among the 183 member countries of ILO, which requires, as per ILO convention number 155 1981, that member countries formulate, implement and periodically review a coherent policy on occupational safety and health and work environment.
Ghana has not yet rectified this convention and the nation has no established authority dedicated to Occupational Safety and Health to guide and facilitate the implementation of the “Action at the National Level” as indicated in the R164 Occupational Safety and Health Recommendation, 1981.
OH legislation vague
However, the Labour Act 2003, Act 651, Part XV, sections 118 to 120 apparently directs employers and employees in their roles and responsibilities in managing Occupational Health, Safety and Environment, but is not specific about whom to report accidents and occupational illnesses to.
It is not clear or does not specify what to consider as Occupational Illness. It does not specify who to be responsible for ensuring the industries in Ghana implement corrective actions as per recommendations.
Accidents that occur in factories are expected to be reported to the Department of Factory Inspectorate but companies hardly report such events to the inspectorate for investigation and correction.
When these accidents get reported, it takes a long time before corrective or preventive actions get implemented, hence, there is a little or no positive effect of the action of the DFI on the factories.
Multinational HS standards enter Ghana
Ghana has seen some positive Safety and Health practice ‘infection’ or advocacy among some Ghanaian companies due to the influx of multinational companies into the country, given their corporate expectations with specific requirements in Occupational Safety and Health practices.
This stems from their requirements for the contractors, and subcontractors, some of whom are Ghanaian, to follow their Health and Safety standards.
The Oil and Gas sector has introduced their side of approach to managing health and safety. This is purely based on risks and it definitely is an improvement on what is existing. In as much as this is a good effort and helps the Ghanaian to know there is more to Occupational Safety and Health than we have specified in our legal framework, it tends to confuse Ghanaians on which standard to follow, and what is required to make employees and employers accountable.
OH not taught in Ghana
In academia, Occupational Health is not an option for specialisation in a typical Ghanaian medical school. Safety engineering has not found its way into any of our Engineering curricula in Ghana yet.
A potential intervention is the proposed Safety and Environmental Engineering program which is being expected to commence at the University of Mines & Technology, but this is not approved yet.
OHS training at low level
Safety & Health training programs are run either by international agencies or some Ghanaian organizations but none of these match up to even a first degree, and the big question is, to what Ghanaian standards are these courses being run?
When do we say a provision made by a company meets requirement and what requirement would we be measuring against or what do we call Ghanaian standard?
When do we say a company has exhibited due diligence in preventing harm to a worker, and under what circumstance a worker has been or not been negligent regarding an undesired event? Suggested Approach to Occupational Safety & Health Management in Ghana.
Ghana sheq policy needs
Ghana should adopt or develop a broad base Occupational Safety and Health policy that is in line with the ILO convention 155 as a minimum. This must seek to address Safety and Health issues regarding all projects and operations from design stage, through procurement, construction, operation and decommissioning.
The aim of this must seek to first protect the worker from injuries and work related ill-health, ensure standards are put in place to prevent losses property damages due to accidents, and must show the Ghana Government’s commitment.
Achieving this means all the scattered generic Occupational Safety and Health requirements under the different agencies of the Ghana Government such as the Environmental Protection Agency, Department of Factory Inspectorate, Inspectorate Division of The Ghana Minerals Commission and the Ghana Labor Commission with confusing responsibilities must be brought under a common umbrella body.
Such a body must be empowered and resourced adequately to enable them organize how the policy would be implemented nationwide and by whom.
This policy must be authenticated by the Ghana Government and form part of the nation’s legal document.
Ghanaian health and safety organisations
Consultation effectiveness with relevant organistions must support implementation of the expected Ghana National Occupational Safety and Health Policy. The relevant organisations may include Ghana Minerals Commission, Ghana Chamber of Mines, Ghana National Petroleum Corporation, Association of Ghana Industries, The Universities, The Department of Factory Inspectorate, Ghana Institute of Engineers, Ghana Medical Association, Ghana Bar Association, Ghana Environmental Protection Agency.
Communicate sheq policy
Communication of outcomes of consultations and requirements of Safety and Health policy could be done through the National Media Commission and associated private and public media.
Competency of the human resource who would be championing the implementation and monitoring of the Occupational Safety and Health policy must be built up. This may require introducing relevant courses like Safety Engineering in Ghanaian universities and Polytechnics as well as Occupational Health in our Medical Schools.
These training institution would need to be adequately resourced and accredited to deliver quality education in Occupational Safety and Health for Ghanaians to be able to manage Occupational Safety and Health issues.
Collaboration between the industry, the public and the established body responsible for the implementation, management and monitoring of the policy is paramount.
Control of the practices with guidelines either adopted or developed by the Occupational Safety and Health body needs specific emphasis. Specific roles and accountabilities with timelines need to be developed for planning and implementation of the Occupational Safety and Health policy actions with clear reporting lines. This must not exclude penalties for intentional non-conformances and negligence.
OHS planning and implementation in Ghana
Actions that need to be made to ensure the achievement of the Ghana national Occupational Safety and Health policy aim and objectives would need to be clearly spelt out with specific timelines, roles and responsibilities.
Targets must be set by the nation, for the various industries and exceeding them should merit controls set by the Government. To guide the industries achieve those targets, there has to be guidelines in areas like emergency preparedness, hazardous material management, risk assessments, accident reporting and investigation, workplace inspections, workplace exposures monitoring, assessment and control, purchasing and supply chain policies, permit to work systems.
There is the need also to ensure the governing organization is empowered and resourced to proceed with continual research into workplace exposures, levels that should not be exceeded, safe ways of completing the tasks, and improvement of controls when undesired events, conditions or systems are encountered. These must tie into the roles and responsibilities as indicated under the organization and it has to be specific.
OHS evaluation in Ghana
After the nation has adequately implemented the above recommendations or their appropriate alternatives, there has to be effective monitoring of the implementation of the process as per the specified standards, compliance by the industry, identification of opportunities for improvement, and recommendation of effective and applicable corrective or improvement actions.
Health and safety improvement in Ghana
Actions identified as necessary to be implemented in order to improve upon the identified gaps and inadequacies must be implemented as required. The implementation stage also requires monitoring by the governing body. The body need to be resourced with tools, equipment and skilled labour to ensure the implementation is done to required standard.
OHS auditing in Ghana
At all the implantation stages of the National Occupational Safety and Health Policy, there has to be effective periodic monitoring. This requires auditing all the stages of the national occupational safety and health management system periodically to ensure continuous improvement.
Ghana has fragmented Occupational Safety and Health legal requirements under the jurisdiction of different agencies yet has no national policy and body responsible for monitoring and ensuring that requirements and guidelines in occupational safety and health are implemented.
Ghana would derive moral, economic and legal benefits from forming an OHS authority or organisation, including prevention of loss and suffering of Ghanaian workers.
• This post is based on a paper by Joe-Steve Annan (MSc QSE, BSc Chem Eng, American Industrial Hygienists Association member), published on Ghana Web at the end of 2010, titled ‘Occupational and industrial safety and health’.